Increasing competition in the pet medicines market: the CMA's proposed potential remedies
The Competition and Markets Authority (CMA) published a 162-page working paper (Remedies Vets Market investigation Working Paper on 1 May 2025. It sets out the potential package of 28 remedies that may be needed to achieve a shift in the commercial relationship between veterinary businesses and pet owners. The purpose of the working paper is to consult on the likely impact of the remedies being considered. (Deadline for responding to the consultation 27 May 2025). This page (written by Andrea Tarr, Founder and Director of Veterinary Prescriber) provides a summary of the proposed potential remedies and other key points. Follow the link to read the full paper.
Scope of the review
The report notes that any orders the CMA might make as part of the investigation would apply only to the supply of vet services to household pets. They would not place requirements on practices that focus on farm animals or equines, and in mixed practices any orders would only apply to the provision of services for domestic pets. Vet practices would be welcome to take voluntary action and change processes relating to farm animals or equines to align with those for household pets, but they would not be obliged to do so.
The CMA's findings and proposed remedies relating to medicines
The paper covers several aspects of veterinary practice. However, this summary covers only the paper's messages about medicines.
The CMA has identified that medicines dispensed by vets can be costly compared to online pharmacies, with practices making significant mark ups and that consumers could make considerable savings when they purchase medicines from authorised online pharmacies. It found that consumers may face barriers to purchasing medicines from third-party retailers, such as a lack of information on the quality of medicines sold online, or because fees charged by veterinary practices for written prescriptions reduce or eliminate the cost savings from purchasing online. However, even when, in principle, it would be possible to purchase online, many consumers prefer the convenience of buying from their vet. Evidence provided by large veterinary groups shows the top 100 prescription medicine products account for 72% of all prescription medicine revenue on average.
The CMA has concerns about the effects of the barriers on competition in the supply of veterinary medicines. In response, the CMA is considering new market-opening and data-sharing measures that would prompt alternative medicine purchasing behaviour, to help pet owners reduce the costs of medicine purchases and to increase competition in the supply of medicines.
The proposed remedies relevant to medicines are mainly discussed in Section 4 of the paper Increasing price competition in the medicines market [from p80]).
Remedy 7: Introduce measures to provide additional information about the option to purchase medicines online and measures to increase online purchases of medicines. This could be achieved by making it mandatory for vets either to offer, or alternatively to issue a prescription for all medicines subject to limited exceptions. The prescription may then be fulfilled in the original first opinion practice or elsewhere. It is expected that this would encourage investment in systems and processes to make issuing a written prescription at least as efficient as in-practice dispensing.
Remedy 8: Enable transparency of medicine prices so pet owners can compare between first opinion practices and other suppliers. The proposed remedy is for the prescription to contain a link/QR code signpost to a price comparison site together with the average, or lowest price for the medicine (as listed on a price comparison site) printed on the prescription. This is considered the option most likely be sufficiently specific to drive a change in consumer behaviour and increase the competitive constraint on veterinary practices. The link should be specific enough so that the details of the prescription can be imported and do not need to be entered manually. (The report states that the CMA considered the possibility of separating prescribing and dispensing functions but considers this is not currently feasible: no further information is provided).
Remedy 9: Introduce the requirement for generic prescribing (with limited exceptions) to increase inter-brand competition for medicine sales so that consumers have the opportunity to access the cheapest effective medication. The CMA's view is that, where clinically possible, medicines should not be prescribed with reference to a single brand. Rather that medicines are prescribed by generic name, with reference to a therapeutically equivalent, or multiple specified medicines, except in limited instances where it is clinically inappropriate. The CMA notes that it may be possible to implement technological changes that would allow vets to easily see all generic options. For instance, if an e-prescribing solution were implemented, one option is that when a vet selects a particular medicine, the system identifies and lists all generic alternatives for the vet to review and include.
Remedy 10: Introduce controls on the price charged for a prescription. This could be achieved by abolishing or imposing price caps on prescription and dispensing fees. The CMA's view is that if a remedy is introduced that requires the mandatory provision or offer of a prescription, there should be a price control on the level of prescription fees.
Remedy 11: Have interim controls on medicines prices. The CMA's view is that any price control on medicines should be interim and time-limited ( 1 to 3 years). It would aim either to limit further price increases or to reduce them by a limited amount (if it is found that medicine prices are significantly more than would be expected in a well-functioning market).
Other parts of the CMA's report that concern medicines
Remedy 1: Require practices to publish information for pet owners (standardised price list) to include: i) Prescription, dispensing and administration. The CMA wants to explore whether there is scope to further standardise dispensing fees) ii) Medications and chronic conditions. The CMA welcomes views on the specific categories that would be appropriate. Standardisation may not be an absolute requirement to support price transparency or comparability, and it may not always be possible or appropriate.
Remedy 3: Require practices to publish information about pet care plans and minimise friction to cancel or switch: the CMA notes that consumers may struggle to assess whether pet care plans (which typically include flea and worming products and vaccines) are suitable for their needs. The CMA reports that pet care plans are sold on the basis of savings from paying into a plan vs. the cost if all of the included services were purchased separately. However, pet owners are often not able to easily understand how much the services would have cost outside the plan (especially for flea and worm treatments that could be purchased elsewhere with a written prescription). It is likely to be even more difficult for many pet owners to assess how many of these services they are likely to use (or have used in the past year) which is an essential part of working out whether the plan constitutes value for money. As such, pet owners may be paying for pet care plans, and assume that they are making savings, when they would have saved money if they had bought the services on a ‘pay-as-you-go’ basis, outside the plan.
The prescribing cascade? Although the CMA paper on regulation published in February (Regulatory framework for veterinary professionals and veterinary services) discussed the cascade, the remedies paper does not mention the cascade.
What can be achieved?
The potential remedies would aim to open the medicines market to increased competition and create a virtuous circle which would drive down veterinary medicine prices over time by:
Empowering and encouraging consumers to shop around for vet medicines.
Increasing the attractiveness and feasibility of market entry by online pharmacies – and potentially other animal medicine providers beyond vet practices – and to support the expansion of those providers into offering a wider range of drugs.
Creating greater incentives for vet firms to moderate prices and profits associated with medicines, due to the risk of losing business – both in terms of losing the individual transaction for the particular drug and losing the custom
System changes needed to achieve the aims
The CMA's view is that the package of remedies would likely require significant changes to systems, as it will drastically increase the volume of prescriptions being issued (the CMA calculated that up to 27.5 million prescriptions would have been issued had prescriptions been mandatory in 2023) and require prices to be gathered by a price comparison tool and then displayed on the prescription. Implementation of this remedy package would require a system capable of meeting at least the following objectives:
(a) prescriptions are secure and can be redeemed only once; prescriptions do not currently have a mechanism built in to prevent fraud, rather relying on communication between the dispensing pharmacy and prescribing vet.
(b) prescriptions can be generated quickly and efficiently and issued to the customer in the consultation room; some vets do not have efficient systems for prescribing; some do not currently issue prescriptions at the consultation.
(c) prescriptions can be quickly transmitted to pharmacies;
d) prescriptions contain pricing information.
The CMA's preliminary work indicates that there are at least two broad ways of achieving these changes, in addition to the construction of a price comparison tool:
(a) System integration. Each of the six large veterinary groups uses a different practice management system (PMS). The CMA notes that there is insufficient information on the PMS used by the 1000 or so independent practices, although they are more likely to be third-party solutions. The initial view is that system integration is likely to be difficult, time consuming and costly to introduce. However, it may deliver a more efficient prescribing system as information would only need to be entered by vets in one place
(b) A single e-prescription portal. An alternative approach to integrating PMS systems would be for a single new system to be built that is specifically designed for prescriptions. An e-prescription portal is likely to carry lower implementation risk and lower costs than attempting to integrate different PMSs. The e-prescription portal would be integrated with a price comparison tool, to allow it to incorporate information on medicine prices to display on the prescription. The e-prescription portal would be separate from vets’ PMS systems, but vet practices could choose to integrate their PMS through use of APIs
Price comparison tool: A central part of the remedy package is the provision of pricing information to the pet owner. This requires that any prescription system is integrated with a price comparison tool that gathers information on medicine prices from different sources. The price comparison tool would provide information to the e-prescription system and be accessible for consumers with a prescription. Options for e-prescription portal and price comparison tool include: (a) software maintained and operated by an appropriate regulatory body (e.g. RCVS); (b) software maintained and operated by a special purpose vehicle on a non-profit or for-profit commercial basis; (c) vet businesses responsible for independently providing price information to the operator of the software.
The consultation
The CMA wants to hear from stakeholders (by 27 May 2025) about:
ways in which the remedies proposals could be improved
about the practical (or cost) considerations in implementing them
possible unintended consequences
any alternative suggestions to remedy the potential concerns
the timeframe that might be needed, or desirable, to introduce certain remedies
and whether it would be beneficial to test certain remedy options before they are put in place (the CMA has powers to conduct trials of the way some remedies may be implemented. Trials are most likely to be relevant to Remedy 7: Changes to how consumers are informed about and offered prescriptions, and Remedy 8: Transparency of medicine prices so pet owners can compare between first-opinion practices and other suppliers.
The CMA has posed specific questions relating to each remedy, starting on page 151 of the report